## Facts

- American University operated a correspondence-based school marketing chiropractic-related instruction to students nationwide.
- The school’s promotional materials allegedly misrepresented or overstated matters such as expected graduate earnings, institutional prestige, and the existence or character of physical facilities.
- D. E. Wood served as president of the school and was later discharged.
- After discharge, Wood took a leadership role at a competing institution and sent communications to American University’s enrolled students.
- Wood’s communications encouraged students to leave American University and enroll with the competing school.
- The communications also criticized American University’s program and asserted that its advertising and recruiting representations were false or deceptive.
- American University sued for equitable relief, seeking to stop Wood’s solicitation and disparaging communications, alleging interference with its student contracts and injury to its reputation.
- Wood raised the defense of unclean hands, asserting American University’s student contracts and goodwill were procured through misleading advertising.

## Issues

1. Whether a plaintiff whose student relationships and goodwill were allegedly obtained through materially misleading advertising may obtain an injunction against a former officer who solicits the plaintiff’s students and criticizes the plaintiff’s program.
2. Whether the doctrine of unclean hands bars equitable relief when the requested injunction would protect advantages directly connected to the plaintiff’s own deceptive conduct.

## Decision

- The Supreme Court of Illinois affirmed the denial of equitable relief to American University.
- The court held that unclean hands barred the university from obtaining an injunction.
- The court refused to enjoin Wood from communicating with the university’s students or from criticizing the university’s advertising and program in the manner alleged.

## Legal Principles

- A court of equity will deny equitable relief to a plaintiff whose claim is directly connected to the plaintiff’s own wrongful or fraudulent conduct.
- Unclean hands applies where the plaintiff seeks equitable protection for contracts, goodwill, or other advantages obtained through materially misleading representations.
- Injunctive relief is discretionary; a plaintiff seeking an injunction must show equitable entitlement, not merely an asserted legal wrong.
- Denial of equitable relief based on unclean hands may leave unresolved any separate, purely legal remedies not pursued or not framed as equitable relief.

## Conclusion

Because the university’s asserted contractual and reputational interests were found to be tied to misleading recruitment and advertising practices, equity would not issue an injunction that would effectively protect the benefits of that misconduct; unclean hands barred the requested equitable relief against the former officer’s solicitations and criticisms.


Am. Univ. v. Wood, 294 Ill. 186, 128 N.E. 330 (Ill. 1920)